Enabling circularity

through transparency:
Introducing the EU
Digital Product Passport

January 2023
Three DPP publications with different purposes
Focus of this publication
Enabling circularity through
transparency: Introducing the
EU Digital Product Passport
CONTENT
• Introduces EU DPP and objectives
• Summarizes EU DPP status as of
December 2022
• Outlines options for open policy
elements and discusses
implications
PURPOSE
Informs about DPP and shapes regulatory
discussions incl. corporate engagement
Navigating uncertainties of the EU
Digital Product Passport: How to
prepare
now as a company
CONTENT
• Introduces EU DPP from a
corporate lens
• Outlines why companies should act
now and how they can prepare
• Highlights challenges and additional
growth opportunities
PURPOSE
Prepares companies and motivates to
participate in regulatory discussions
The EU Digital Product Passport
shapes the future
of value chains: What it is
and how to prepare
CONTENT
• Summarizes regulatory status
• Illustrates key implications along
electronics value chain
• Highlights actions companies and
the EC can take to prepare for the
DPP
PURPOSE
Informs all readers and combines all
publications
1
Executive summary Introduction EU DPP analysis
Executive summary
Introduction
• A digital product passport (DPP) is a
structured collection of product
related data across a product's
lifecycle to advance the transition to
a circular economy and thereby
support economic growth
• A few examples of DPPs exist, but the
EU is the first regulatory mover at
scale
• EC is currently drafting the DPP
regulation. A first passport for
industrial batteries has been drafted
• First product group expected to be
affected by regulation in 2026/7.
DPPs are expected to be mandatory
for most industries by 2030
• EU DPP regulation is expected to
impact global value chains
Conclusion
EU DPP analysis Conclusion
• Many elements in EU DPP are still open with different levels of maturity, • The EU DPP is a first of its kind
the same applies to the battery passport regulation strong regulatory circularity tool.
However, many questions remain
• Several topics remain unclear and are expected to be answered by the EC: unclear and a long timeline to full
SCOPE implementation is expected
• Product groups: Which industries/product groups should be • In detailing the DPP regulation, a
prioritized and why? balanced approach between
• Company size: Should requirements differ by company size? quickest and optimal options is
• Application level: What level should DPPs be applied at? relevant to enable companies to
TECH prepare for the DPP
• Data storage: How and by whom should data be stored? • Despite the uncertainties and the
• Data carrier: What data carrier(s) should be used? long timeline, companies benefit
• Access/security: How should access to the data be allowed? from preparing for the DPP
implementation now
DATA
• Data requirements: What information/data will be included in
More details can be found in our
the DPP at what degree of standardization?
separate publication:
• Governance: Who collects and updates the data? How is the DPP "Navigating uncertainties of the EU
data verified? Digital Product Passport: How to
prepare now as a company"
2
Content
Introduction 4

EU DPP Analysis 13

Scope 14

Tech 23

Data 35

Conclusion 42

3
Introduction

4
Executive summary Introduction EU DPP analysis Conclusion

DPPs have several They share product information across

functionalities the product lifecycle
Exemplary information shared in a DPP across the product lifecycle1

Raw material producer Brand/Designer

• Deforestation • Origin of raw materials
• Emissions • Recycled vs. virgin
Collect product information across • Water/ground • Resource consumption Manufacturer
the product lifecycle contamination • Water usage
• Emissions
Extract raw • Waste
materials Design • Water/ground
Manu- contamination
facture
Digitally store data (e.g., in the cloud) Distributor
Recycle
• Transport. emissions
• Packaging
Collector/Recycler/ Distri- • (Eco-) labels
Refurbisher/ bute • Waste generation
Provide easy data access to Remanufacturer
stakeholders (e.g., through scannable • Disassembly Collect (Re-)User/Repairer
instructions Use/
QR codes) Repair • Product impact
• Recycling
• User manual
instructions
• Repair instructions
• Repair history
• Disposal instructions

1. Non-exhaustive; this graph has the purpose of illustrating what information a DPP could collect across a product's lifecycle, final DPP information
depends on further specification by the EC. Responsibility for data collection, DPP creation, etc. will be discussed later in this publication (see page 40)
5
Source: BCG analysis
Executive summary Introduction EU DPP Analysis Conclusion
DPP could be a key tool to improve
circularity …
Empowers informed, more environmentally conscious
decision-making across the value chain (VC)
Facilitates effective management of waste flows and EoL1
treatment, thereby increasing recycling rates and access to
recycled materials and products
Enables traceability of environmental impact and thus
more accurate measurement (e.g., scope 3 emissions)
Provides common foundation and clear requirements for
becoming circular
Enables setting and digitally tracking regulatory circular
economy targets and verifying compliance with them
1. EoL: End of life
… and thereby drive
economic value
Creates corporate value through collaboration (e.g., operational
efficiency improvements and innovation of new materials/products,
business models, and markets)
Leads to higher value retention from waste, longer material lifetime,
job creation, and lower raw material dependency, thus mitigating
impacts of supply shocks and price volatilities
Enables more efficient energy and resource consumption and
thereby reduces associated costs for economy, society and env.
Ensures an equal level playing field, enhances visibility and credibility
of sustainable products, and decreases VC deficiencies
Spurs digital capability development of authorities, thereby increasing
the efficiency of regulatory processes and reducing resource spending
6
Executive summary Introduction EU DPP analysis Conclusion

EC proposes DPPs as first regulatory …but DPP draft remains vague

mover at scale… with slow timeline
Final approval of DPP regulation expected in 2023/4
Several examples exist (e.g., Madaster, KEEP), but with delegated act for first product group to come
most of them are early stage and industry-specific, into force 2026/72; a first product passport has been
with no regulatory examples or broader drafted for batteries3
implementation1
DPP regulation expected to be drafted for majority of
industries by 2030 with exception of 7 product
EC is the first large regulator aiming for mandatory categories (e.g., food)4
DPPs to promote the transition to a circular
economy, provide new business opportunities and DPP regulation expected to have a global impact due
support consumers to global nature of supply chains and as other
regulators might follow the EU example

However, DPP implementation poses significant Final DPP format and content remain unclear at this
challenges for EC to implement given little learnings point
to build on the broad intended cross-industry scope
and the complexity of DPP set-up
Scope: EU regulation to also include eco-design &
performance requirements → DPP as tool to
facilitate those and thus core focus of this publication

1. Based on analysis of 25 DPP examples 2. Most likely those highlighted in CEAP incl. electronics and ICT, batteries and vehicles, textiles, plastics, construction and buildings; despite mentioned in CEAP, packaging is not
expected to have a separate delegated act 3. The battery passport will come into effect for industrial and electrical vehicle batteries first from early 2027 4. Full list of categories excluded from DPP regulation: Food, feed, 7
medicinal products, veterinary medicinal products, living plants, animals and micro-organisms, products of human origin, products of plants and animals relating directly to their future reproduction; Source: Company/initiative
websites; European Commission, ESPR proposal, BCG analysis
Executive Summary Introduction EU DPP analysis Conclusion

Eco-design for Sustainable Products Regulation (ESPR) establishes EU DPP

and is key link between policies
Illustrative1
Empowering Consumers in the
Green transition Horizontal level
Relates to general rules
Sustainable Corporate about aspects across broad
ESPR builds on several Governance range of products
Union policies
Replaces Eco-design Directive, REACH rules that govern ESPR complements and
extending the scope and covering chemicals concretely reinforces
European Green Deal broader range of products horizontal initiatives by
specifying general rules
Market Surveillance Regulation
Eco-design for Sustainable
EC's 2020 industrial Upcoming initiative on
Products Regulation (ESPR),
strategy Green Claims Product-specific level
which establishes a DPP Refers to legislation for a
specific product or a well-
Circular Economy Product-specific legislation (e.g., defined product group
Action Plan (CEAP) Eco-design batteries, detergents, and toys))
Directive
ESPR takes targeted action to
EU Textile Strategy specific product/product value
ESP Battery Battery
measures Directive Regulation chain needs or problems
Circular Electronics

1. The chart illustrates relationships between key policies and initiatives but is not exhaustive 8
Source: European Commission, European Union, ESPR proposal, BCG analysis
Executive Summary Introduction EU DPP analysis Conclusion

European Commission plans first product group regulation

to come into force in 2026/7
Prioritized industries based on CEAP
Possible to submit Electronics & ICT, batteries & vehicles, textiles,
plastics, construction & buildings4
opinion on proposal1

2023/4
Final approval Regulatory drafting by product group
April ‘22
First reading expected3
First reading2 TBD 2026/7 2027 2030
commenced in (no deadline)
Additional DPP to come into DPP required for
EU Council DPP mandatory on
readings2 effect for initial industrial & electric
textiles sold in EU
product group(s) vehicle batteries

2022 2023 2024 2025 2030

First reading
(no deadline) 2024-2027 2028-2030
March ‘22 TBD TBD
Drafting of ~7-14 new Drafting of 6-12 new
Adoption by First reading2 in Conciliation
delegated acts5 delegated acts
European European Committee
Commission Parliament Delegated acts per product group likely to be developed separately (even within
industries), resulting in low alignment of acts and high complexity for companies

1. To rapporteurs, members of committee, any MEP or during public hearings 2. EC proposals can earliest be adopted after first reading by both EU Council and
European Parliament 3. EC aims at reaching final approval latest before the 2024 European Parliament Elections 4. Packaging will not be regulated by a separate 9
delegated act but covered as component of products across product groups 5. Initial ambition by EC were covering 3-4 delegated acts per year, but based on interview
with the EC 2-3 acts seem more realistic; Source: European Commission, ESPR proposal , CEAP, BCG analysis
Executive summary Introduction EU DPP analysis Conclusion

DPP has global impact beyond EU borders

Typical supply chain for consumer electronics Illustrative

1 Metals imported, rare earth metals 5 Camera, Compass, LCD screen imported
mined in China1 from Japan
2 Screen, flash memory from South Korea 6 Wi-Fi chip, Audio Chips imported from
USA EU DPP with global impact as
3 Accelerometer imported from Germany regulation will be applied to
7 Final assembly and testing in
Shenzhen, China imported products, its components
4 Near field communications controller and intermediary products the same
from the Netherlands way and at the same time as to
domestic ones

1 EU DPP may inspire additional

3,4
2 regulation globally thus potentially
6,7 1,2, 5
4,5,7
applying to even broader scope of
3
2
companies and value chains in the
future
1
1

1. One country is specified as an example for each material/component, but the map shows more regions of materials/components origin 10
Executive summary Introduction EU DPP analysis Conclusion

Many elements in EU DPP still open with different levels of maturity;

similar picture for battery regulation
Battery regulation drafted as first product group act;
likely to inform further regulatory development
Open topics Key questions Status of EU DPP regulation Battery passport regulation
• Some industries prioritized/excluded • All types of batteries on the market
Which industries/product groups
1 Product groups should be prioritized and why? • Prioritization of product groups and • Categories are revised and updated to reflect
remaining industries unclear developments in market and use
Scope Should requirements differ by • Implementation across company sizes
2 Company size • Same requirements for all companies
company size? • Differentiation & SME support unclear
What level should DPPs be applied • DPP level defined per product group
3 Application level at? • Every battery shall have a battery passport
• Preferred application level unclear
How and by whom should data be • DPP storage to be company-managed • Rules for accessing, sharing, managing, etc.
4 Data storage stored and managed? • Requirements for DPP storage unclear of data are yet to be established
• List of options tbd by product group • QR code and/or physical smart label
Tech 5 Data carrier What data carrier(s) should be used?
• Standardization and format unclear • Labels on packaging for too small devices
How should access to the data • Differentiated access per VC actor • Consumers, independent operators, etc.
6 Access/security be allowed? • Details on data access levels unclear • Further details should be developed
• Requirements to be specified by • Carbon footprint, minimal recycled content
Data What information/data will be
product group in delegated act of scarce raw materials, etc.
7 included in the DPP at what degree
• •
requirements of standardization? Clear definitions of data points missing Details about information, KPIs and
Data and standardization unclear measurements developed in next 2 years
• Economic operator placing product on
Who collects and updates the data? • Econ. operator placing battery on market
8 Governance How is the DPP data verified? EU mkt.to collect & update DPP data
• No information on verification or validation
• Data verification remains unclear
Degree of maturity in EU DPP regulation3 Degree of maturity in EU battery regulation

1. Product model 2. Bluetooth 3. Fully grey Harvey ball indicates a topic is fully undefined, fully blue indicates a topic is fully defined 11
Source: European Commission, ESPR proposal, Battery Regulation proposal, BCG analysis
Executive summary Introduction EU DPP analysis Conclusion

A range of options for EC to consider when mandating or recommending

solutions in upcoming policy

Open topics Option space Option assessment in next chapter Expected type of EC regulation

1 Product groups
Scope
2 Company size
3 Application level
Product group by product group Industry by industry Mandate Clear guidance needed on
what/who is in scope, which
Large corporations Large level to measure at and how
Across all companies Mandate
first corporations only to treat imports. This is
essential to be fully aligned
Item Batch Product model Mandate across VCs.

1 EU-managed Company-managed Different tech solutions can

4 Data storage1 Recommend exist next to each other as
2 Centralized Decentralized long as min. requirements are
Tech met e.g., DPP success does
Bluetooth not require one prescribed
5 Data carrier QR code Barcode RFID Watermark NFC Recommend
tags data carrier
Clear guidance needed on
6 Access/security Full access Minimum access Differentiated access Mandate who obtains what data access

Data Standardization of Specification per Min. requirements need to be

7 Combination Mandate mandated for relevant aspects of
Data requirements data requirements product group data topics to ensure impact of
DPP –additional data
8 Governance No assurance Limited assurance Reasonable assurance Mandate points/assurance could be
voluntary

Faster implementation is important due to the urgency of Faster implementation2 Current EC proposal
increasing circularity and the positive cost impact for companies–
however a balance with other aspects is key (see next chapter)

1. Refers to data storage beyond a EU-managed DPP registry that will be established for compliance purposes; no judgement on speed of implementation of remaining data storage as company-managed
may take longer than EU-managed, whereas early movers likely to be quicker than EU 2. Regulatory and/or corporate implementation 12
Source: European Commission, ESPR proposal, BCG analysis
EU DPP analysis

13
13
Executive summary Introduction EU DPP analysis Conclusion

Open topics Key questions

Which industries/product groups should be
1 Product groups
prioritized and why?
Should requirements differ by
Scope 2 Company size
company size?

3 Application level What level should DPPs be applied at?

Scope Tech
4

5
Data storage

Data carrier
How and by whom should data be stored?

What data carrier(s) should be used?

6 Access/security How should access to the data be allowed?

Data What information/data will be included in

7
requirements the DPP at what degree of standardization?
Data
Who provides and updates the data?
8 Governance
How is the DPP data verified?

Degree of maturity in EU DPP regulation

Click to navigate Fully grey: Fully undefined
through this document Fully blue: Fully defined

14
14
Executive summary Introduction EU DPP analysis Conclusion
Product groups 1
Product groups | DPPs implemented per product group
with unclear approach
EC status Battery passport regulation Degree of maturity in EU DPP regulation2

Priority industries defined; product group prioritization unclear
• DPP implementation per product group1 (EC definition
remains unclear, e.g., laptops vs. handhelds)
• Prioritized industries but no indication on how EC
approaches DPP implementation within industries
Timeline expectations Expected type of regulation
Product group prioritization until Mandate for clear guidance
end of 2023; first regulation for on what is in scope and full
products expected in 2026/7 value chain alignment
Open questions
• What product groups exist? How do
industries break down into them?
• Which product groups are
prioritized and why?
• How long will it take to develop
and implement delegated acts per
product group?
Categories and their prioritization are decided Degree of maturity in EU battery reg.
• Encompasses all batteries and accumulators
• Larger batteries (e.g., industrial and electric vehicle ones)
will have DPP, but implementation for smaller ones unclear
• Revisions and updates to follow Implications for companies
• Varying DPP requirements for
Implications for other products
• The EC will implement delegated acts per product group,
companies covering multiple
rather than industry level, similar to battery draft, product groups
• Multi-year drafting process likely per product group
• High level of uncertainty about
prioritization, implementation
Options No EC proposal yet
timeline and definition of
product groups
Industry by industry
Product by product group
Product groups prioritized based
Product groups within a prioritized • Companies in prioritized
industry (e.g., electronics) covered
on level of their environmental
first, followed by product groups
industries can start
impact, regardless of the industry
in another industry preparations despite
uncertainties

Key actors Standardization • Corporate involvement in

regulatory discussions can help
• European Commission to prioritize product groups • Existing international approaches and EC regulations shape EC mandate in line with
• NGOs (e.g., WBCSD) to provide industry input and related to product standards to be taken in the account
environmental implications for harmonization preferences

1. The EC defines product groups as "a set of products that serve similar purposes and are similar in terms of use, or have similar functional properties, and are similar in terms of consumer perception"; how this
definition will translate into the final breakdown of industries into product groups currently remains unclear 2. Fully grey Harvey ball indicates a topic is fully undefined, fully blue indicates a topic is fully defined
15
Source: European Commission, ESPR proposal, Battery Regulation proposal, BCG analysis
Executive summary Introduction EU DPP analysis Conclusion
Product groups 1

First prioritized industries are outlined

…but product
Unmentioned Excluded from DPP
group prioritization
Prioritized industries1 remains undefined
industries regulation

Breakdown of industries
Electronics & ICT Food and feed into product groups
A number of industries remains unclear
Medicinal products and
(e.g., cosmetics) are not veterinary medicinal
Batteries & vehicles
mentioned in the EC documents products Draft framework for priori-
but nevertheless likely to be
included in the DPP at a later stage Living plants
tizing product groups to be
Textiles published by EC early 2023
Animals and micro-
Plastics organisms Prioritization of product
groups to be finalized by EC
Products of human origin by end of 2023
Furniture
Products of plants and
Packaging will not be regulated by animals relating directly Delegated acts per product
Construction and buildings
a separate delegated act, but will to their future group likely to be
be covered by regulation as reproduction developed separately (even
component of a product placed on
within industries) resulting
the market3
Chemicals2 in low alignment and high
complexity for companies

1. Based on industries prioritized in Circular Economy Action Plan 2. EC's impact assessment accompanying the ESPR proposal
3. Gwenole Cozigou, Director at the European Commission’s internal market department 16
Source: European Commission, ESPR proposal
Executive summary Introduction EU DPP analysis Conclusion
Product groups 1

Going industry by industry allows for higher alignment and speed of

regulatory development
No EC proposal yet
Product by product group Industry by industry
Description
Product groups prioritized based on level of their Product groups within a prioritized industry (e.g., electronics)
environmental impact, regardless of the industry covered first, followed by product groups in other industries
Advantages/Disadvantages Low speed, given the complexity of the regulatory
Higher speed since delegated acts for product groups
drafting and differences between product groups, may
Speed of regulatory development within one industry will overlap and could be ‘re-used’
take multiple years per group, especially if delegated acts
leading to higher alignment and predictability
are not aligned
Companies active in several similar or different value
chains cannot benefit from synergies of the Better synergies for companies active in several product
Impact on companies implementation across product groups; potentially more groups of one industry; no significant time delays
costly due to larger timespans and low alignment among between delegated acts; less costly
delegated acts
High when environmental impact is the main driver for Potentially lower but prioritizing industries by
Environmental impact prioritization; total impact may be offset by slower environmental impact and speed of implementation with
implementation potential positive impact on environment
Key considerations
High environmental impact, but low regulatory speed and Faster implementation and higher alignment leads to
alignment leading to limited synergies for companies corporate synergies at potential risk of lower impact

Disadvantage Advantage Combination

Source: BCG analysis 17

Executive summary Introduction EU DPP analysis Conclusion
Company size 2
Company size | EC plans to implement DPP regulation
across all companies
EC status Battery passport regulation Degree of maturity in EU DPP regulation1

Limited company size angle on DPP implementation Regulation applies to all companies regardless of size Degree of maturity in EU battery reg.
• No specific details about whether EC plans different • Requirements are the same for all companies
degrees of implementation depending on company size • Assistance provided to SMEs where necessary to reduce
• High-level measures to reduce regulatory burden for SMEs regulatory burden
are outlined Implications for companies
• Implementation across all
Timeline expectations Expected type of regulation Implications for other products
All companies of one product Mandate for clear guidance • SMEs expected to be affected by regulation at the same
companies raises question
group expected to be covered by on who is in scope to time as large corporations about how the value chain
DPP regulation at the same time align expectations will cover costs and who will
pay these
Open questions Options
• Particularly for SMEs, early
• Will company size play a role in the EC proposal preparation for DPP
DPP implementation?
Implementation for Implementation for implementation is important
• Should requirements differ by Implementation across
large corporations large corporations
company size? all companies
first, SMEs follow later only, SMEs excluded
• Leveraging the influence
• How will implementation be
facilitated for large corp. vs. SMEs?
of industry associations
for advising the EC on
feasibility is key for SMEs
Key actors Standardization
• Corporate involvement in
• European Commission to define scope for companies • DPP regulation likely to be applicable across all companies regulatory discussion can
• Companies and industry associations can advise on regardless of size due to no further specification by EC and
practicality and feasibility of DPP, specifically for SMEs stance taken in battery regulation shape how and when SMEs
are covered in mandate

1. Fully grey Harvey ball indicates a topic is fully undefined, fully blue indicates a topic is fully defined 18
Source: European Commission, ESPR proposal, Battery Regulation proposal, BCG analysis
Executive Summary Introduction EU DPP analysis Conclusion
Implementing DPP across all companies enables transparency
across the full value chain
EC proposal
Implementation across
all companies
Description
DPP regulation will apply to all companies DPP regulation will apply to large
regardless of size
Advantages/Disadvantages
Medium due to effort required from
Speed of regulatory development EC if support for SMEs specified; all
companies covered by DPP earlier
Higher data availability and reporting
Large corp. efficiency as data can be obtained
Impact on from all VC actors
companies Highly complex and costly as procuring
SMEs resources and developing new
capabilities is required
High as full transparency and
Environmental impact1 traceability enables circularity and
cross-stakeholder collaboration
Higher transparency and traceability
Transparency and traceability
can be achieved across VC
Key considerations
Full transparency and data availability at Fast implementation traded off for the
high complexity for SMEs, thus likely
Disadvantage Advantage requiring additional support
Combination
1. Will depend on stakeholder role and impact in respective VC
Source: BCG analysis
Implementation for large
corporations first
companies first, SMEs follow later
Medium as drafting is quicker for large
corp. only, but additional regulation
likely required for SMEs later on
High initial investments for setting up
DPP infrastructure but opportunity to
shape the level playing field first
Short-term avoidance of costs and
learnings from large corp. but long-
term investments needed
Delayed environmental impact as DPP
only covers larger VC actors at first;
might slow down the process of
transitioning to a circular economy
Partial transparency and traceability at
first, increases at later stage
opportunity to bring full transparency
and impact of the DPP to the VC
immediately
Company size 2
Implementation for large
corporations only
DPP regulation will apply to large
companies only, SMEs excluded
Lower complexity for EC as fewer more
homogeneous stakeholders involved,
but complexity shifted to large corps
Higher complexity and costs for large
corp. due to need for additional
resources to collect/estimate data
No regulatory pressure but large corp.
could make data provision a condition
for doing business
High due to quicker implementation
but low if SMEs are key to full DPP
implementation across VC
Limited transparency and traceability
as SME data is not collected fully
Fast implementation and unclear
environmental impact at the cost of
pressure in the VC, and lower
transparency and traceability
19
Executive summary Introduction EU DPP analysis Conclusion
Application level 3
Application level | EC does not specify one preferred
application level for DPPs
EC status Battery passport regulation Degree of maturity in EU DPP regulation3

EC plans to apply DPP at item, batch or model level Regulation stipulates unique passport per battery Degree of maturity in EU battery reg.
• EC does not specify which level is preferable across product • Each individual battery1 placed on the market or put into
groups, but will decide for each group separately service shall have a unique battery passport
• This will depend on the complexity of the VC, the size, • However, certain data points (e.g., carbon footprint, %
nature or impacts of the respective products recovered materials) can be reported on batch level Implications for companies
• Companies might need to
Timeline expectations Expected type of regulation Implications for other products
No specification on timing of Mandate for clear guidance • Item-level application of DPP as outlined in battery
prepare for implementing
decision-making, likely in line on DPP level required for regulation not necessarily realistic for all other products different DPP levels per
with acts per product group VC alignment (e.g., chemicals) product group
• For initial guidance, companies
Open questions Options No EC proposal yet
could look at the battery
• Which level will the DPP be passport regulation for an
applied at? Batch
Item
Items grouped together Product model item-level DPP as this could
• What needs to be considered when Each individual piece
implementing the decision for a identified by unique Items sharing e.g., serve as a blueprint for future
with unique identifier
certain DPP level? batch number share same GTIN2 share DPP EC delegated acts
has a unique DPP
DPP
• Companies and industry
associations could advise the
Key actors Standardization EC on the practicality and
• European Commission to define application level • DPP level expected to be specified for each product group feasibility of DPP levels for
• Corporates and industry associations can give guidance separately industries/product groups
on practicality and feasibility of options • Degree of standardization possible across product groups
within one industry

1. Industrial, EV & light means of transport batteries prioritized 2. Stands for Global Trade Item Number which can be used to identify types of products 3. Fully grey
Harvey ball indicates a topic is fully undefined, fully blue indicates a topic is fully defined 20
Source: European Commission, ESPR proposal, Battery Regulation proposal, BCG analysis
Executive Summary Introduction EU DPP analysis Conclusion
Application level 3

Decision on application level will impact the way

DPPs work across VCs

Product model
Key considerations
• One common identifier for all items of same
PRODUCT MODEL • The level at which the DPP
model (e.g., each model XY1 laptop carries
(e.g., all Model XY1 laptops) same ID number) will be applied has significant
• Data carrier of each item links to same product implications on the number of
info (e.g., avg. microplastic release) DPPs generated, the
granularity of data made
Batch available in the DPP and the
BATCH 1 BATCH 2 potential for downstream
• Common identifier for all items of one batch
(e.g., each model XY1 laptop from plant A traceability of products
(e.g., all XY1 laptops from (e.g., all XY1 laptops from
plant A) plant B) carries same ID) • The application level
• Data carriers of different batches link to
can significantly increase
different batch info
the complexity of DPP
implementation for companies
Item
ITEM 1 ITEM 2 ITEM 3 ITEM 4
(e.g., one (e.g., one (e.g., one (e.g., one • Unique identifier for each individual item
XY1 laptop) XY1 laptop) XY1 laptop) XY1 laptop) (e.g., each XY1 laptop)
• Data carriers of different items link to different
item information (e.g., repair history)

21
Executive Summary Introduction EU DPP analysis Conclusion
Application level 3

DPPs can be applied at the level of an item, batch or product model

EC plans to define application
level per product group1
Description
Advantages/Disadvantages
Speed of regulatory development
Impact on companies
Environmental impact
Transparency and traceability
Key considerations
Disadvantage Advantage
Combination
Item level
DPP applies at item level
An item can be an individual piece that
has a unique identifier
Slow due to high complexity and need
to implement DPP for each individual
item across industries/product groups
High complexity and costs as unique
identifiers need to be created per item
and EoL operators would have to scan
each individual item
High as detailed data is available that
creates higher transparency on
material value and potential circularity
of products (e.g., item repair history)
High as data is specific and directly
linked to each individual item;
technically each item could be tracked
individually but downstream
traceability limited in EoL processes1
Offers high level of transparency at lower Adds complexity at medium
speed of regulatory development and environmental value and transparency
high complexity for corporates
Batch level
DPP applies at batch level
A batch includes a group of items that
share a unique batch number
Moderate speed as batch likely easier
to define and implement due to
prevalent practices
Moderate complexity and costs as less
DPPs need to be created and batch
documentation widely exists
Limited if environmental impact of
products occurs downstream, but high
if impact occurs upstream, due to
transparency and data availability
Medium as data is aggregated per
batch and thus less specific; tracing
possible as long as batch is not taken
apart (e.g., during upstream VC stages
but not during use/EoL)
Product model level
DPP applies at product model level
Product model can be items that have the
same GTIN
Higher speed as DPPs per model can
be created and defined based on
existing standards (e.g., GTIN)
Greater synergies as one DPP created
for all items of one model which
lowers complexity and costs
Low, as impact can only be unlocked if
largest env. impact comes from design
stages incl. material sourcing, as
limited tracking possible beyond that
Low as data reported on model level is
likely less accurate and no traceability
possible, since models are typically
produced over long time spans and
could only be traced in batches
Unlocks speed and synergies at cost of
transparency, traceability and impact

1. Industry-wide standardization could ensure consistent DPP implementation, reduce complexity and increase user-friendliness, but could limit environmental value if
harmonized at batch/model level 2. EoL operators (e.g., disassemblers, recyclers) process large amounts of waste bulk- or weight-based, so scanning each individual item does 22
not seem realistic in the short-run due to need for significant investments and process redesigns
Source: BCG analysis
Executive summary Introduction EU DPP analysis Conclusion

Open topics Key questions

Which industries/product groups should be
1 Product groups
prioritized and why?
Should requirements differ by
Scope 2 Company size
company size?

3 Application level What level should DPPs be applied at?

Tech Tech
4

5
Data storage

Data carrier
How and by whom should data be stored?

What data carrier(s) should be used?

6 Access/security How should access to the data be allowed?

Data What information/data will be included in

7
requirements the DPP at what degree of standardization?
Data
Who provides and updates the data?
8 Governance
How is the DPP data verified?

Degree of maturity in EU DPP regulation

Click to navigate Fully grey: Fully undefined
through this document Fully blue: Fully defined

23
Executive summary Introduction EU DPP analysis Conclusion

DPP data needs to be collected, stored and accessed by actors along the
value chain

DATA TECH
8 4 5
Data collection Data storage1 Data carrier

Economic operator placing 8 DPP data made accessible

good on the EU market
legally required to collect
& provide required data
7
Data
requirements
Clearly defined data
points required for
each DPP
8 Data governance
Data verification DPP data stored by EU or
companies in databases through machine-
(e.g., cloud/blockchain) readable data capture
DPP data verification medium (e.g., QR code)
required (through econ.
operator or third party)
6
Data access
8
Level of access to DPP
Data update
data could e.g., differ by
VC stakeholder group
Economic operator placing
good on the EU market legally
required to update DPP data
Topic relation - click to see
# an overview of the topics

1. Data storage refers to DPP data required beyond the information provided in the EU-managed registry for compliance purposes. Thus, while unique IDs per product will be stored
in the registry, additional product information incl. emissions and the like needs to be stored separately. 24
Source: European Commission, ESPR proposal, BCG analysis
Executive summary Introduction EU DPP analysis Conclusion
Data storage 4
Data storage | EC proposes company-managed solution
for DPP data storage
EC status Battery passport regulation Degree of maturity in EU DPP regulation4

EC plans to set up a registry, but leave storage to companies Battery DPP info will be stored in an EU-owned system Degree of maturity in EU battery reg.
• EC plans to set up and maintain a standardized DPP registry • EC plans to set up the electronic exchange system for
to store a list of unique identifiers at the minimum1 rechargeable industrial and electric vehicle batteries
• Remaining DPP data to be stored by companies with no • Future acts will establish system's architecture & “rules for
specification of preferred data storage yet accessing, sharing, managing, exploring, publishing”2 Implications for companies
• High uncertainty regarding DPP
Timeline expectations Expected type of regulation Implications for other products
Design and testing of the registry Recommendation incl. a list • It is yet unclear if the electronic exchange system will be
systems and associated cost
throughout 2025 and of storage option(s) with standardized across product groups. It only applies to
• Potential issues with
implementation in 2026 defined min. requirements specific batteries within the battery product group
data security and safety in
relation to IP protection,
Open questions Options3
confidentiality, etc.
• Who will set up, own and EC proposal
1 manage the platform for DPP data? 1 EU-managed platform for DPP data
Company-managed • Investments may be needed
solutions for DPP data
How will responsibilities be divided? to set up and integrate DPP
systems with existing systems
• What technologies shall be used for Centralized storage Decentralized storage on multiple
2 data storage?
2 (e.g., on cloud or on-premise) computers (e.g., blockchain)
(highly complicated if
No EC proposal yet blockchain)

Key actors Standardization • Given EC is expected to

recommend guidelines not to
• European Union to decide DPP systems and • EC aims to have a standardized registry for all products, mandate a solution, companies
implementation including at least a list of unique identifiers
• Specialized IT service providers • Beyond the registry, the EC is planning limited can start preparing now
• Corporates & NGOs (e.g., WBCSD) can provide inputs standardization with leaving data storage to companies

1. Final format of EU registry yet to be specified thus currently unclear whether data beyond unique IDs will be collected in this registry. 2. EC, Battery Regulation Proposal 2. Two
sets of possible options are analyzed. Set 1 related to responsibility of platform set-up, ownership and mgmt., set 2 related to options for storage technologies 3. Fully grey Harvey 25
ball indicates a topic is fully undefined, fully blue indicates a topic is fully defined; Source: European Commission, ESPR proposal, Battery Regulation proposal, BCG analysis
Executive summary Introduction EU DPP analysis Conclusion
Data storage 4
Company-managed solutions offer higher flexibility
but require clear EC guidance to ensure interoperability
EC proposal
EU-managed platform Company-managed solutions
Description
EU sets up, owns and manages a unified platform for storing all Companies determine themselves how to store and manage DPP
DPP data, which companies provide and access data through data, following EC's overarching guidance and principles
Advantages/Disadvantages1
Would require a one-off administrative cost by the EU for No cost for the EU, but (financial) might will be needed,
…the EU
setting it up and continuous investments in maintenance especially for SMEs
Cost for…
No cost for the setup, but investment will be needed for Companies will have to invest; cost will vary depending on the
…companies aligning and integrating existing IT infrastructure with the EU chosen solution, collaboration with other stake-holders to
platform create a system or usage of third-party platforms

Relatively easy to implement across product groups and VCs
due to standardized platform across product groups, but
Ease of implementation
companies will need to change their IT setup to ensure
interoperability with EU platform
Although potential to leverage existing IT systems, there is
high risk of creating multiple different solutions within value
chains and product groups leading to significant complexity
(for e.g., EoL operators needing to access multiple platforms)

Easy to standardize across different product groups, Difficult to standardize, as companies can choose different
Standardization potential industries and value chains but potential limits to adopting options; standardization only possible through voluntary
solution to product group, VC or industry needs collaboration across the VCs, product groups and industries

Collecting all DPP data in one designated EU platform allows Large number of potential solutions requires suppliers and
VC accessibility easy access for all VC stakeholders (once sufficient IT EoL operators to access multiple portals in order to utilize and
infrastructure is in place) provide DPP data, significantly increasing complexity
Key considerations
A unified platform may take time to create and result in an Adopting company-managed solutions requires clear EC guidance
inefficient system if not co-designed with companies to enable (e.g., based on a data exchange protocol2) to avoid development
interoperability and automation of multiple competing, costly and incompatible solutions
Disadvantage Advantage Combination

1. Speed of regulatory development and environmental impact not analyzed here, as they are likely to differ only slightly between both options
2. For an example of a data exchange protocol please refer to the WBCSD-hosted Partnership for Carbon Transparency (PACT)
26
Source: BCG analysis
Executive summary Introduction EU DPP Analysis Conclusion
Data storage 4

Regardless of who manages the solution, cloud and blockchain could

be used for DPP data storage

Centralized system Decentralized system

all data is stored on servers the data is stored on multiple
in-house or on cloud computers (or nodes) connected
through a decentralized storage network

On-premises On cloud Blockchain

• More costly to maintain • Cost savings ~30-50% Blockchain is an energy-intensive

but more control over data • Data security improved due technology and energy consumption could
• Data security at risk to frequent tech updates increase exponentially if used for many
• Data loss potential products across multiple VCs, potentially
impacting environment adversely in sum1
Cloud and Blockchain are not
Given the high energy consumption of storing large data sets,
exactly mutually exclusive options
green clouds and data centers should be considered to increase and could be used in combination
the sustainability when the clear goals of the
solutions are defined.
The crucial difference is in the
availability of Blockchain protocols,
Given the similarity between cloud and on-premises as well as
i.e., rules that define interactions,
shift towards storage on cloud by enterprises, only cloud maintain security and cannot be
compared with blockchain in the following overwritten in the network.

1. Additional studies are required to assess the environmental impact of the blockchain technology 27
Source: BCG analysis
Executive summary Introduction EU DPP analysis Conclusion
Data storage 4
Cloud offers significant benefits due to ease of implementation
and low cost
No EC proposal yet
Cloud solutions1 Blockchain
Description
Centralized data storage on remote storage systems Decentralized data storage across products’ life cycle with
consistent record shared in real time across all participants
Advantages/Disadvantages2
Currently lower energy consumption per transaction than Currently higher energy consumption per transaction, but
Environmental impact
blockchain, but overall impact depends on implementation full impact depends on implementation
Transparency More difficult to ensure high levels of transparency and Guaranteed transparency and traceability as data cannot
and traceability traceability; governance required be changed once added; real-time visibility
Lower cost as solutions are widely adopted and utilized High implementation costs and expensive tracking at an
Cost
by companies/regulators already individual product level (e.g., portable charger)
Not used by companies at scale; integration with existing
Easier and faster as already widely used; requires
tech is unclear; all actors in one VC would need to agree to
some alignment between different actors to ensure
Ease & speed of implementation use one blockchain; different tech maturity across VC slows
interoperability; could easily be standardized across
down adoption and increases potential resistance; but
industries; but limited automation capabilities
possibility to automate processes and eliminate errors
Data security Higher risk of a data breach and network failure Data cannot be altered; low chance of network failure
Possible to create different permission levels for Ability to maintain privacy where needed and control by
Permissioned access
different stakeholders whom, when and how data can be accessed
Key considerations Lower price and wider adoption of cloud solutions can speed Although blockchain offers transparency and data security
up DPP implementation, however, requires governance of benefits, cost and complexity of implementation likely to
data security and transparency to mitigate risks outweigh them, making it a less realistic solution for DPPs
Disadvantage Advantage Combination

1. Similar advantages apply for on-premise data storage (see page 27)
2. Speed of regulatory development not analyzed here, as it is likely to differ only slightly between both options 28
Source: The Energy Consumption of Blockchain Technology: Beyond Myth (2020), Sedlmeir, Buhl, Fridgen, et al.; BCG analysis
Executive summary Introduction EU DPP analysis Conclusion
Data carrier 5
Data carrier | EC plans to specify data carrier(s) per
product group
EC status Battery passport regulation Degree of maturity in EU DPP regulation4

General guidance on data carrier Battery regulation suggests use of QR codes Degree of maturity in EU battery reg.
• List of data carriers will be specified per product group • The QR code will be printed or engraved on all batteries,
• Will be released in accordance with international standards providing access to a battery’s passport
• Shall comply with the ISO/IEC standard 15459:20151 • It should respect the guidelines of ISO IEC Standard 180042
and Directive (EU) 2019/88233 Implications for companies
• Implementation is currently
Timeline expectations Expected type of regulation Implications for other products
No specified timeline, likely in Recommendation incl. list • Same identifier(s) could similarly be adopted for other
unclear as highly dependent on
accordance with delegated acts of carrier options with product groups list of carriers per product
per product group defined min. requirements • Exceptions will be in place for very small products group
• Lack of clarity on how new
Open questions Options No EC proposal yet
carriers will be combined
• What data carrier(s) should with/differentiated from
be used? Bluetooth
QR code Barcode RFID Watermark NFC current labels
• Will it be the same for all tag
product groups? • Potential to impact EC
• How will smaller products
be identified?
recommendation by setting
industry standards or engaging
in regulatory discussions
Key actors Standardization
NFC tags and Bluetooth tags have not
• European Union to propose data carrier(s) • EC will likely aim for some degree of standardization to limit
• Corporates & NGOs (e.g., WBCSD) can provide inputs number of accepted data carriers
been mentioned in the EC regulation but
• ISO to provide guidance on standardization show a lot of potential in a number of
industries in the future

1. Standards on Information technology, Automatic identification and data capture techniques, Unique identification 2. Defines the requirements for a QR Code 3. Accessibility
requirements for products and services 4. Fully grey Harvey ball indicates a topic is fully undefined, fully blue indicates a topic is fully defined; Source: European Commission,
29
ESPR proposal, Battery Regulation proposal, BCG analysis
Executive summary Introduction
QR code offers benefits but is not the single best option
No EC proposal yet
Description
Advantages/Disadvantages
Cost
Ease & speed of implementation
Data storage feature
Durability
User-friendliness
Key considerations
EU DPP analysis Conclusion
QR code
A machine-readable matrix code
that links to information
Slightly higher cost than of a
barcode, but among most
affordable and effective
options on the market
Easy and quick to implement,
already used by many players
Mainly used as trigger to a
webpage but able to provide
info on condition of the product
Can sustain up to 30% of
structural damage and still
continue to function
Can be easily scanned by
smartphones. Widely used by
customers already
Currently seems to be the most
effective option on the market
Source: BCG analysis
Options mentioned by the EC
Barcode
A machine-readable code in the
form of numbers and a pattern of
parallel lines
Most affordable option
Easy and quick to implement,
already present on most
products
Able to tell only a product’s
number
Highly depends on the label
material and print quality
Can be easily scanned by
smartphones
Less durable and lower data
storage than other options but
widely used across many VCs
RFID
A wireless communication system
comprised of tags and readers
The typical tag is not expensive
but has to be implemented
together with scanners/readers,
which increases the cost
Harder and slower to implement
across the VC due to the reader
tech, mostly used in warehouses
Tags can store up to 128 kilo-
bytes at increasing prices the
more data is stored – enough
to store basic DPP data
Under normal conditions, most
tags can function for 20 years
or more
Only a couple of mobile
phones can scan the tag,
special scanner is needed
Can bring a lot of value for the
whole VC but ease of access
needs to be solved
Disadvantage
Data carrier 5
Digital watermark
Imperceptible codes, the size of a
postage stamp
Cost may vary, shows a lot
of potential for low value
products
Moderately easy & quick to im-
plement, less widely used; useful
for sorting of low value items
Able to carry wide range of attri-
butes (e.g., manufacturer, SKU,
type of plastics used & compo-
sition for multilayer objects)
Depends on the surface it is
applied to, but details remain
unclear
A high-resolution camera is
needed during sorting. Unclear
how consumers can access data
Can store much data, but
durability and cost remains
unclear
Advantage Combination
30
Executive summary Introduction EU DPP analysis Conclusion
Data carrier 5
Although not mentioned by the EC, NFC and
Bluetooth tags could have potential
Additional options to consider, not mentioned by the EC
No EC proposal yet
NFC Bluetooth tags
Description
A sticker with small microchips and antenna that can be read ‘Microcomputers’ the size of a postage stamp that power
by mobile devices themselves by harvesting radio waves from nearby device
Advantages/Disadvantages
Rather expensive at about twice the price of an RFID tag, The most expensive solution among all presented data
Cost
but does not require extra reading equipment carriers, but might get more affordable in the future

Easy and quick to implement given their small size on a Harder and slower to implement due to their novelty, at
Ease & speed of implementation
range of different products the moment only works paired with cloud solutions

Every tag has a memory chip. Amount of info stored Do not store data. When there is no energy nearby, they
Data storage feature depends on the tag type, ranges from 48 bytes to 1 will not transmit data. Highly dependent on the data
megabyte. Most commonly used as a trigger to a website transmission to the cloud

Some tags last 4 years. Battery-free options may last

Durability Has a lifespan of over 10 years
longer but still unclear

Can be read by most smartphones. A user needs to bring

Captures data within 10 m range, can be read via any
User-friendliness in their phone within the range of 0.1 m and will be
existing Bluetooth devices
presented with data
Key considerations
Potentially easier to use than other tag but limited to small Provides value for all stakeholders across value chain. Works
distances; so far has been widely adopted for payments best when combined with AI in the cloud and machine learning
Disadvantage Advantage Combination

Source: BCG analysis 31

Executive summary Introduction EU DPP analysis Conclusion
Data access 6
Data access | Will differ by stakeholder group with
details yet to be specified
EC status Battery passport regulation Degree of maturity in EU DPP regulation1

Data access to be differentiated by VC stakeholder group Differentiated access proposed Degree of maturity in EU battery reg.
• Different access levels per stakeholder group (e.g., • Key data points to be publicly accessible (incl. carbon
customers, manufacturers, governments, etc.) footprint information, battery lifetime, etc.)
• Still unclear which group should have access/no access to • Additional data points restrictively accessible to accredited
what data and how privacy is ensured economic operators, the EC or authorities Implications for companies
• Data access levels will have
Timeline expectations Expected type of regulation Implications for other products
Timeline unclear, but likely in line Mandate for clear guidance • Product group properties are likely to be considered when
significant impact on data
with data requirements by on which actor has access providing access security, privacy and IP Data
product group act to what data • Different actors likely to have different levels of access transparency across supply
chain and can optimize how
Open questions Options players along the VC
• What stakeholder group should get EC proposal
collaborate
access to what data? Minimum access
Differentiated access • EC plans restricted transparency
• How are data security (e.g., IP) and Full access (strictly on a need basis
stakeholder/user privacy ensured? based on stakeholder for customer, thus limited
for all stakeholders e.g., limited access for
end users)
needs impact on demand expected
• Corporate involvement in
regulatory discussions can
Key actors Standardization shape EC mandate on access
• European Union to draft regulation for data access • EC plans to specify access rights at product group level, level per VC actor
• NGOs & consultancies (e.g., WBCSD) can provide insights thus, limited standardization across product
on what data is required by what stakeholder groups/industries and potentially VCs

1. Fully grey Harvey ball indicates a topic is fully undefined, fully blue indicates a topic is fully defined 32
Source: European Commission, ESPR proposal, Battery Regulation proposal, BCG analysis
Executive summary Introduction
Differentiated access allows to ensure data and IP protection
while ensuring DPP impact
Description
Advantages/Disadvantages
Speed of regulatory development
Impact on companies
Environmental impact
Data security/privacy
Key considerations
Disadvantage
EU DPP analysis Conclusion
Full access
Allows full data access of information
stored in DPPs to all stakeholders along
the entire VC
Speeds up implementation by
requiring less regulation as access
level is the same across VC
Risks for companies from loss of IP
and potential revenue implications
through increased transparency if
high environmental impact
High environmental impact from
full transparency across value
chain enabling VC collaboration
and circularity
Full access could pose risk to security
of sensitive data (e.g., IP protection,
end user privacy, etc.)
High environmental impact at risk of
data protection and security
Data aggregation currently not mentioned in EC's ESPR proposal but could be relevant to balance data security,
Advantage Combination transparency and readability of DPPs by combining multiple detailed data points into one aggregated data point
Source: BCG analysis
Minimum access
Allows restricted access to minimum data
needed to exclusively increase circularity
(e.g., low/no transparency for users)
Slows down implementation as EC
needs to specify data needs and
access levels per product group
Highest degree of IP protection and
low revenue implications from
limited customer transparency
Lower environmental impact, due to
missing customer transparency and
limited ability to promote circularity
across the value chain
Allows to protect data by making
the minimum required data points
available to each stakeholder
High levels of data security at the cost of
environmental impact
Data access 6
EC proposal
Differentiated access
Grants differentiated levels of access
to each stakeholder group based on their
needs and decisions they need to make
Moderate speed of implementation
due to differentiated access which
can likely be standardized across
product groups
Allows for IP protection, but potential
implications on revenues from
market tendencies towards less
environmentally impactful products
High environmental impact by
enabling transparency across
supply chain with lower degree of
VC collaboration possible
Protects highly sensitive information
and associated security risk (e.g., by
aggregating data points)
Ensures protection of sensitive data
while unlocking environmental impact
33
Executive summary Introduction EU DPP analysis Conclusion
Data access 6
Data needs differ by VC stakeholder and decisions
they need to make BCG analysis based on Metabolic system data maps; not EC view

STAKEHOLDERS DPP PURPOSE DECISIONS MADE (not exhaustive) DATA NEEDS

raw mat.
Extract

Decisions on raw material extraction/production practices required that will impact demand of raw materials but does
Raw mat. producers not lead to specific data needs from other VC actors

Brands • Product design (incl. • Use of materials, Env. impact of raw

Design

Circular design longevity, circularity, parts & packaging materials, parts &
Product designers recyclability, etc.) • Choice of suppliers components

• Choice of energy usage, emissions & Info on raw mat.,

facture

Manufacturers
Manu-

Sustainable source/consumption waste management

parts & components
Assemblers production • Decisions on water • Factory placement Manufacturing info

Importers/Distributors • Choice of • Choice of packaging Manufacturing info

Distri-
bute

Transparency transportation mode

Retailers • Choice of products Product info

End users/Reusers Transparency • Choice of products • Decision (on how) Product info
Repair
Use/

• Decision to to dispose/whether
Repairers Material circularity repair/keep/update to resell/recycle Use & repair

Collectors • Decision on (degree • Degree of recycling Disassembly

EoL

Material circularity of) disassembly vs. landfilling

Recyclers/Remanuf. • Decision to remanuf. • Up- vs. downcycling Recycling

Authorities Transparency • Actions on non-compliance Compliance info

Source: Metabolic system data maps, BCG analysis 34

Executive summary Introduction EU DPP analysis Conclusion

Open topics Key questions

Which industries/product groups should be
1 Product groups
prioritized and why?
Should requirements differ by
Scope 2 Company size
company size?

3 Application level What level should DPPs be applied at?

Data Tech
4

5
Data storage

Data carrier
How and by whom should data be stored?

What data carrier(s) should be used?

6 Access/security How should access to the data be allowed?

Data What information/data will be included in

7
requirements the DPP at what degree of standardization?
Data
Who provides and updates the data?
8 Governance
How is the DPP data verified?

Degree of maturity in EU DPP regulation

Click to navigate Fully grey: Fully undefined
through this document Fully blue: Fully defined

35
Executive Summary Introduction EU DPP Analysis Conclusion
Data requirements 7
Data requirements | Overarching areas suggested,
but details remain undefined
EC status Battery passport regulation Degree of maturity in EU DPP regulation4

First data topics suggested without clear definitions Initial topics suggested with specific definitions still lacking Degree of maturity in EU battery reg.
• EC plans to implement different data points per product • General areas for data reporting proposed
group1 in specific delegated acts • No specific guidelines or definitions on what
• Data topics outlined without specifications on data and how to report
presentation and definition Implications for companies
• Limited ability to foresee
Timeline expectations Expected type of regulation Implications for other products
First regulated products with Mandate incl. a list of min. • Similar areas likely to be covered for other products
& prepare for data
detailed data requirements required data points with • Specifics and degree of standardization remain unclear requirements, but EC
expected by 2026/7 voluntary additions mandate likely based
on existing EU requirements
Open questions Options and global standards
• What data will be included in the EC proposal • Unclear degree of
DPP at what degree of Combination
Standardization Specification
Most data require- standardization across
standardization? Data requirements Data requirements set
• How will the data need to be ments standardized products could lead to high
largely the same across independently per
presented? product groups product group
with product-specific complexity, especially for
additions/exemptions companies producing across
product groups
Key actors Standardization • Uncertainty of required data
• European Union to define data requirements and degree of • EC plans for low degree of standardization might add cost and reporting
standardization • Data points to be specified per product group rather than complexity as decisions made
• CIRPASS, UNECE2, CENCENELEC3, Corporates, NGOs across product groups and industries today might need to be revised
(e.g., WBCSD), etc. can provide inputs/recommendations

1. The EC defines product groups as "a set of products that serve similar purposes and are similar in terms of use, or have similar functional properties, and are similar in terms of consumer perception"; how
this definition will translate into the final breakdown of industries into product groups currently remains unclear 3. European Committee for Standardization 4. Fully grey Harvey ball indicates a topic is fully 36
undefined, fully blue indicates topic is fully defined; Source: European Commission, ESPR proposal, Battery Regulation proposal, BCG analysis
Executive Summary Introduction EU DPP Analysis Conclusion
Data requirements 7
EC proposes long list of relevant data topics without providing
clear data points or definitions
Proposed data topics1 Link to battery passport
Performance & durability parameters No clear definitions
• Durability and reliability
(incl. min. avg. duration, exp. lifetime) of data topics
• Ease of repair, maintenance, upgrading, re-use,
remanufacturing and refurbishment
• Ease and quality of recycling Level of recycling, recycling
• Avoidance of technical solutions detrimental to efficiencies & recovered materials
reuse, upgrading, repair, etc. No detailed data points
• Use of substances Content & location of hazardous substances specified (even in EU
• Consumption of energy, water & battery passport)
other resources Consumption of (electric) energy
• Use or content of recycled materials
• Weight and volume of the product and its Information regarding
packaging (incl. product-to-packaging ratio) components & materials No ambition to standardize
• Incorporation of used components across product groups
• Quantity, characteristics & availability of
consumables needed for use & maintenance
• Environmental footprint along entire lifecycle
Little insights into data
• Microplastic release
requirements for product
• Emissions to air, water or soil Total carbon footprint & intensity
groups beyond batteries
• Carbon footprint (kg & kg/kWh)
• Amounts of waste generated incl. packaging
waste (and ease of re-use) & hazardous waste Collection of waste batteries For a more detailed overview of data points that
• Conditions for use may become relevant for the EU DPP, please
reach out to a BCG contact listed on page 46

1. A separate list of complementary data points connected to technology/identification has been proposed by the EC (incl. unique product identifier, etc.) 37
Source: European Commission, ESPR proposal, Battery Regulation proposal, BCG analysis
Executive summary Introduction
A mix of standardization and specification allows
for impact and simplified implementation
Description
Advantages/Disadvantages
Speed of regulatory development
Impact on companies
Environmental impact
Transparency
Key considerations
EU DPP analysis Conclusion
Standardization
The data points required will largely be
the same across all product groups
Speeds up process of drafting and
updating regulation, but does not
allow for tailored updates
Allows for preparation and learnings
across product groups, allows roll-out
across multiple product groups at the
same time thus reducing complexity
Earlier implementation across large
number of product groups, but
standardized data points may be of
limited relevance for specific products
Limited transparency at high
comparability of data points
Process advantages that risk
environmental impact & transparency
Source: BCG analysis
EC proposal
Specification
Different data requirements will be
detailed separately for each product
group
Slows down drafting process, but
allows for tailored updates per
product group
Limited ability to prepare and is highly
complex, especially for companies
operating across product groups,
which may lead to inconsistencies
within industries/VCs
Impact from tailored reporting on key
material topics relevant for each
specific product group, at a delay due
to prolonged regulatory drafting
High transparency at limited
comparability of data points
High impact from tailored regulation that Balance between process optimization
complexify implementation
Data requirements 7
Combination
A list of general data requirements will be
standardized across product groups/
industries with additions/exemptions per
product group
Slows down drafting process, but
allows for tailored updates per product
group
Allows for preparation, but some
complexity remains as companies
need to report a number of specific
data requirements per product group
Optimized impact due to early
implementation paired with
overarching relevance and tailored
reporting
High transparency and comparability
of key data points
and environmental impact
Disadvantage Advantage Combination
38
Executive summary Introduction EU DPP analysis Conclusion
Data requirements 7

EC can build definitions on existing global

standards

Data point defined1 Standard/protocol Level of definition What exists

GHG emissions Corporate/VC/city level Eco-design requirements for specific
product groups, industry-led DPP
examples as well as reporting standards
Land-based emissions Corporate level (e.g., SBTI, CDP) and guidelines (e.g., EU
guidelines on non-financial reporting)
incl. some data point definitions at a
% recycled materials Corporate level
corporate level

Water use &

Corporate level
contamination Biodiversity
What is missing
CTI V3.0 Corporate/business unit/
% material circularity
factory level Definitions for all data points required
in DPP or, where corporate-level
Product level
Recyclability definitions already exist, product-level
(for plastics & packaging only)
definitions informed by existing globally
Non-exhaustive acknowledged standards

1. Examples, not recommendations 39

Source: Company websites, BCG analysis
Executive summary Introduction EU DPP analysis Conclusion
Data governance 8
Data governance | Collection of data defined but
verification remains unclear
EC status Battery passport regulation Degree of maturity in EU DPP regulation2

Responsibility for data collection outlined, but no data Economic operator responsible for data quality Degree of maturity in EU battery reg.
verification considerations in current EC proposal • No information on verification or validation
• Economic operator placing product on EU market to collect • Economic operator that places battery on the market
and provide DPP data and register DPP in EU registry1 ensures that the data included in the battery passport is
• Limited considerations on data verification accurate, complete and up-to-date Implications for companies
• In case of assurance companies
Timeline expectations Expected type of regulation Implications for other products
Unclear timeline, likely in line Mandate for clear guidance • Data collection and provision likely in line with battery
likely to face higher costs and
with delegated acts per product to ensure data quality and passport thus responsibility of economic operator complexity
group availability
• Assurance will ensure
verification and quality of DPP
Open questions Options No EC proposal yet
data thus enabling trust and
• How is data verified? collaboration across VCs
• By whom is data verified No assurance
(i.e., third-party auditor or not)? self-regulatory
Limited assurance
Reasonable assurance • Assurance more likely to be
for specific DPP
implementation
data points
for all DPP data linked to data points with
with spot checks performance requirements in
the future

Key actors Standardization • EC mandate likely impacted by

assessment of feasibility from
• European Union to provide guidance on data verification • High potential for standardization across product groups companies and industry
• Specialized consultancies & auditors can provide insights as validation of data quality is needed across product
on what level/cadence of data verification is realistic groups, industries and value chains associations

1. The operator placing the product on the EU market is legally required to collect and provide DPP data and register the DPP, however, technically the DPP can be created earlier in the value chain to unlock
synergies of data sharing and transparency 2. Fully grey Harvey ball indicates a topic is fully undefined, fully blue indicates a topic is fully defined
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Source: European Commission, ESPR proposal, Battery Regulation proposal, BCG analysis
Executive summary Introduction EU DPP analysis Conclusion
Assurance enables data quality at cost and complexity for companies
No EC proposal yet
No assurance1
Description
Self-regulated DPP implementation where Assurance of a number of key data points
economic actors are trusted to provide
accurate data
Advantages/Disadvantages
Medium, as no assurance-related
Speed of regulatory development regulation needed, but self-regulatory
framework should be implemented
No additional cost and reduced
Impact on companies complexity for companies, as no third
party needs to be involved
Likelihood of data quality issues may
Environmental impact limit transparency, product circularity
and thus environmental impact
Data quality issues likely to occur due
to limited auditing abilities of
Data quality
companies (esp. SMEs) and potential
tempering of data
Typically, low trust among VC actors
VC collaboration
thus limiting VC collaboration
Key considerations
Easy implementation for companies at
risk of data quality, spot checks may
counteract disadvantages in short-run
1. Likely not a feasible option in the long run and once the DPP is linked to performance requirements that companies will be held accountable to
Source: BCG analysis
Data governance 8
Limited assurance Reasonable assurance
Assurance of all data provided
specified by the EC to ensure the data by the economic actor to ensure data
quality of those quality and validity of DPP data
Medium speed, as regulation for Low speed, as detailed assurance
limited insurance and definition of regulation needed and significant
data points required support for companies required
Additional cost, lower speed of data High additional cost, low speed of data
provision and moderate complexity provision and increases complexity
from involving third party due to involving a third party
Unlocks environmental impact by High data quality and accuracy ensures
ensuring quality of key data points transparency and thus higher
while minor quality issues may remain environmental impact from circularity
Ensures high quality of key data points Enables high data quality across
(important once DPP linked to perfor- companies and VCs with low potential
mance requirements); potential quality of data tempering (important once DPP
issues with remaining data points linked to performance requirements)
Trust in key data points will increase Enables high levels of trust among VC
with VC collaboration to lesser degree actors that will likely increase
than reasonable assurance collaboration across VC
High quality of key data points at High data quality and environmental
moderate cost and complexity; unlocks impact at increased cost and complexity
environmental impact for companies
Disadvantage Advantage Combination
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Conclusion

42
42
Executive summary Introduction EU DPP analysis Conclusion

In sum, EU DPP is a first of its kind regulatory circularity tool,

yet with many open questions and long timeline
… but requires further clarification
and fast(er) implementation
• Unclarity across many aspects makes
actions for early corporate adopters more
difficult as future requirements are not
EU DPP is on a good way to predictable
drive circularity … • Involvement of companies and industry
representatives will ease implementation
• EU DPP is a strong tool to drive circularity
and increase impact
and economic value through transparency
• Building on existing standards and
• EU is a first mover on implementing a
corporate practices is a key enabler
large-scale regulatory DPP requirement
• Initial elements outlined in overarching
regulation and first product group
examples exist
• Strong interest from non-governmental
players

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Executive summary Introduction EU DPP analysis Conclusion

Illustrative

Implementation for all

… focusing on large companies first
companies brings benefits but creates significant impact quickly
(e.g., data availability) …

… batch or product level application

Item level application enables
In detailing DPP highest transparency across VC …
but might be sufficient for many VCs
and faster to implement
regulation
a balance between Definition of data points per … standardizing key data points
product group enables focus on but allows for earlier implementation
optimal set-up and respective highest impact topics … and lower complexity
easier and quicker to … a shorter list facilitates and
implement alternatives Requiring a long list of relevant data
points maximizes transparency …
but speeds up implementation and
is important for the EC impact on those most crucial topics

to consider Setting clear targets and … collecting data and creating

performance requirements based but transparency are relevant
on DPP data will drive impact … starting points

Complex system of restricted data

… easier access to key data points
access and aggregation of data but enable transparency quickly
drives business security and trust …

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Executive summary Introduction EU DPP analysis Conclusion

Being an early adopter, even moving ahead of regulation creates

corporate value
Despite uncertainties and given the ongoing regulatory process, a
range of actions are non regret moves, e.g.,
• Engage in shaping the regulation through direct engagement
Despite with the EC or collaboration across the VC
uncertainties • Assess data availability and fill in the gaps
and long timeline, • Enable own organization to take the right decisions and
companies can optimize processes in light of the upcoming requirements,
prepare for DPP e.g., ensuring synergies, engaging suppliers, …
• Plan for changes in technology ensuring interoperability of IT
implementation systems
now
See separate publication for more
guidance for companies on how and
why to act now

45
 Merle Stepke-Müller
Project Leader,
Authors
Circular Economy
stepke.merle@bcg.com
Alexander Meyer zum Felde
Partner & Associate
Director, Global Lead
Circular Economy
meyer.zum.felde.alexander@bcg.com
Holger Rubel
Managing Director & Sr.
Partner, Sustainability &
Circular Economy
rubel.holger@bcg.com

Maayke Aimée Damen Jeff Turner Lonne van Doorne

Driving insights through Director, Circular Economy
damen@wbcsd.org
Senior Advisor Associate

collaboration
Diana Sukailo Marie Holtorf Friederike Eggert
Consultant Associate Associate
The WBCSD and BCG want to thank
the authors and contributors
involved in the creation of this
publication for their extensive
Beyond that, the WBCSD and BCG want to thank the contributors to this article, especially the WBCSD
contributions Contributors stakeholders, BCG experts as well as the external organizations involved in this collaboration for
contributing their time and knowledge.

This publication is the result of a collaboration by WBCSD stakeholders, BCG experts and external
contributors. The intention of this set of publications is to educate about the upcoming EU DPP
regulation, highlighting current uncertainties incl. what aspects can still be impacted and outlining key
Disclaimer immediate actions for companies to prepare. A range of stakeholders was interviewed and reviewed
drafts. Input and feedback from stakeholders listed above were incorporated in a balanced way. This
does not mean, however, that every stakeholder agrees with every view. This is the best knowledge as
of December 2022 but changes to DPP topics can occur quickly.

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